Declaration of Conformity (PPWR)

The Declaration of Conformity, usually abbreviated DoC, is a written statement required under Article 39 of the Packaging and Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40). From August 12, 2026, such a declaration must exist for practically every item of packaging placed on the EU market.

With the Declaration of Conformity, the manufacturer confirms that the packaging meets the substantive requirements of Articles 5 to 12 of the PPWR, for example regarding substance restrictions, material minimization, recyclability, and, where relevant, reusability. The declaration refers to harmonized standards or, where these do not yet exist, to other technical specifications or internal test methods, and follows the template set out in Annex VIII of the regulation.

Responsibility for the declaration lies with the manufacturer as defined under the PPWR, that is, the party whose brand or name appears on the packaging. By signing it, this party assumes full legal responsibility for the packaging's conformity. The Declaration of Conformity and the underlying technical documentation must be kept for at least five years after the last placement on the market for single-use packaging, and at least ten years for reusable packaging, and made available to market surveillance authorities on request.

The Declaration of Conformity affects not only traditional packaging manufacturers but also brand owners and importers who place packaging on the market under their own name, since manufacturer obligations fall to them in that case. Companies should therefore clarify early with their packaging suppliers how the necessary substance and material data for the declaration will be provided.

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